Corrective Action Plans

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Name of auditee: Bishop (CSI) Non-Profit Housing Corporation HUD auditee identification number: 044-11134 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Anne Sackrison Position: Chief Executive Officer Telephone number: 5...
Name of auditee: Bishop (CSI) Non-Profit Housing Corporation HUD auditee identification number: 044-11134 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Anne Sackrison Position: Chief Executive Officer Telephone number: 586-753-9052 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding #2025-001: Effective May 1, 2025, the required monthly deposit to the reserve for replacements increased from $12,539 to $63,106 based on the capital needs assessment and replacement reserve analysis. The Corporation did not increase the monthly deposits and as of June 30, 2025, the reserve for replacements account is underfunded by $99,135. Comments on the Finding and Each Recommendation: Management should transfer $99,135 from the operating account in order to bring the reserve for replacements account current. Action(s) taken or planned on the finding: Agreed. On July 1, 2025, management transferred $99,135 to the reserve for replacements account.
Finding #2025-002 – Significant Deficiency and Other Noncompliance – Reporting. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.959, Passed through Texas Health and Human Services Commission, All contracts, Contract years: 09/01/23 – 08/31/24 and 09/...
Finding #2025-002 – Significant Deficiency and Other Noncompliance – Reporting. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.959, Passed through Texas Health and Human Services Commission, All contracts, Contract years: 09/01/23 – 08/31/24 and 09/01/24 – 08/31/25. Condition and context: In our testing of a sample of monthly billings and quarterly reports from throughout the fiscal year, we noted that reports were not being submitted within the required timelines for several reporting periods. Management communicated their delays to Texas Health and Human Services Commission (THHS), and their plan to rectify the delays. Phoenix Houses of Texas were able to file all delayed quarterly reports and monthly billings prior to June 30, 2025. THHS has approved all the delayed monthly billings and quarterly reports. Recommendation: Re-emphasize internal controls over timely grant billing and reporting to comply with grant contracts. Planned corrective action: All outstanding billings were subsequently submitted and billings are now current and submitted in accordance with required timelines. Corrective actions implemented include updates to Finance Department policies and procedures to formalize month-end closing and billing timelines and to strengthen oversight and monitoring controls. These changes ensure that billing and reporting are performed on a timely and ongoing basis. Responsible officer: Drew Dutton, CEO and Anunoy Mou, Finance Director. Estimated completion date: Completed September 2025.
Finding #2025-001 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Assistance Listing #14.218, Passed through Harris County, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Gra...
Finding #2025-001 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Assistance Listing #14.218, Passed through Harris County, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #’s: C2023-006G, C2024-006H, and C2020-050G, Contract years: 10/23-09/24, 10/24-09/25, and 03/24-09/24. Assistance Listing #14.218, Passed through City of Houston, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #: 4600016648, Contract year: 05/25-06/25. U. S. Department of Health and Human Services, Assistance Listing #93.576, Passed through Episcopal Migration Ministries, Refugee and Entrant Assistance Discretionary Grants, Contract #’s: 90RP0117‐01-00, 90RP0117-02-00, 90RP0117-03-00, and 90RP0117-04-00, Contract years: 10/23-09/24 and 10/24-09/25. Applicable state program: Texas Department of Agriculture, Home-Delivered Meal Grant Program, Contract #’s: HDM2024029-070-071 and HDM2025052-053, Contract years: 02/24-01/25 and 02/25-01/26. Condition and context: During our testing of 24 expenditures requiring procurement, we identified one instance of expenditures in Home-Delivered Meal Grant Program greater than the simplified acquisition threshold of $10,000 where simplified acquisition procedures in accordance with Interfaith Ministries’ policy were not followed. Recommendation: Emphasize adherence to established policies and procedures to ensure procurement is performed according to the procurement policy, and that proper procurement documentation is maintained. Planned corrective action: Our organization implemented a robust procurement policy effective July 1, 2018 that complies with the guidelines of 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Procurement Standards 200.317-326 and the Texas Grants Management Standards. Under the established procurement method for small purchases between $10,000 and $100,000, Interfaith Ministries is required to obtain price or rate quotations from a minimum of three sources. The management team will re-emphasize the established policy and procedures for procurement with Interfaith Ministries staff. Responsible officer: Sheroo Mukhtiar, Chief Executive Officer and Stephanie Alvarez, Chief Financial Officer. Estimated completion date: December 1, 2025
Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.566, Passed through Texas Office for Refugees, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Contra...
Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.566, Passed through Texas Office for Refugees, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Contract #’s: FFY2024-27947V-CMA and FFY2025-27947V-CMA, Contract years: 10/23-09/24 and 10/24-09/25. Condition and context: Interfaith Ministries’ policies and procedures for verifying the completeness of documentation includes ensuring the acknowledgement of receipt of a debit card by the client is maintained in the client file. In a sample of 33 client files tested for refugee cash assistance program, we noted one client who received a debit card in February 2025 did not have the acknowledgement receipt in the client file. Recommendation: Emphasize adherence to established policies and procedures to ensure acknowledgement of receipt of a debit card by the client is maintained in the client file. Planned corrective action: With the implementation of the Refugee Cash Assistance (RCA) Debit Card program by TXOR, our organization established the policy that client case files must contain a copy of the Debit Card Activation Page with the client’s signature and the date the card was delivered to the client as required by TXOR. Our program team will re-emphasize these policies through additional staff training to ensure compliance with the established policy and procedures for the RCA Debit Card program. Additionally, our compliance department will establish procedures to perform periodic reviews to ensure that the client files are complete. Responsible officer: Ali Al Sudani, Chief Program Officer and Terry Merriett, VP of Quality Assurance & Compliance. Estimated completion date: December 1, 2025.
Finding 2025-003: Subrecipient Monitoring Condition: The Sponsoring Organization did not consistently perform the required initial on-site review for new subrecipients (centers and FCC providers) within the mandatory 28-day timeframe. View of Responsible Officials: 4C agrees with the audit finding. ...
Finding 2025-003: Subrecipient Monitoring Condition: The Sponsoring Organization did not consistently perform the required initial on-site review for new subrecipients (centers and FCC providers) within the mandatory 28-day timeframe. View of Responsible Officials: 4C agrees with the audit finding. Corrective Action Plan: 4C will implement a new process of requiring the first visit for new providers to be conducted by the 20th of the month with notes required in kidcare system related to scheduling and rescheduling of visit. Responsible Party: Pagie Runion, Strategic Director of Business Services Anticipated Completion Date: June 30, 2026
ST. LANDRY PARISH HOUSING AUTHORITY 509 Carriere St. Washington, LA 70589 Phone No. (337) 826-7207 Fax No. (337) 826-0760 HOUSING AUTHORITY OF ST. LANDRY PARISH, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Corrective Action Plan Finding: Finding 2025-001-Per Diem Improperly Paid Condit...
ST. LANDRY PARISH HOUSING AUTHORITY 509 Carriere St. Washington, LA 70589 Phone No. (337) 826-7207 Fax No. (337) 826-0760 HOUSING AUTHORITY OF ST. LANDRY PARISH, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Corrective Action Plan Finding: Finding 2025-001-Per Diem Improperly Paid Condition: Expenditures must be ordinary and necessary, and in accordance with the mission statement terms outlined in the Authority’s Annual Contributions Contract (ACC). Section 14 (B) states “No funds of any project may be used to pay any compensation for the services of members of the HA Board of Commissioners.” Corrective Action Planned: I am Angela Beverly, Executive Director and Designated Person to answer this finding. We will comply with the auditor’s recommendation. Person responsible for corrective action: Angela Beverly, Executive Director Telephone: (337) 826-7207 Housing Authority of St. Landry Parish Fax: (337) 826-0760 509 Carriere St. Washington, LA 70589 Anticipated Completion Date: June 30, 2026
Condition: The Corporation failed to refund a security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded, and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are return...
Condition: The Corporation failed to refund a security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded, and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely. Contact person responsible for corrective action: Sean Alexander, Vice President – Housing Accounting Completion Date: January 22, 2025
Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2025 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Sche...
Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2025 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2025-002 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation. Please see below for action taken. (b) Action taken: Management will reach out to HUD to request a wavier of the delinquent amount of $52,634. If the request does not get approved, Management will work towards an acceptable resolution.
Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2025 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Sche...
Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2025 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (1) Finding 2025-001 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation. Please see below for action taken. (b) Action taken: Management will deposit the delinquent amount of $3,000 into the reserve for replacements account by the end of January 2026.
Management will make adjustments to the policy surrounding the procedures regarding the quarterly review of the bank ratings for finanical institutions during the fiscal year ended September 30, 2026.
Management will make adjustments to the policy surrounding the procedures regarding the quarterly review of the bank ratings for finanical institutions during the fiscal year ended September 30, 2026.
The new property manager now has access to the EIV system and is including the required The new property manager now has access to the EIV system and is including the required documents in the lease files and master files.
The new property manager now has access to the EIV system and is including the required The new property manager now has access to the EIV system and is including the required documents in the lease files and master files.
RE: Capital Fund Program Financial Reporting Finding Corrective Action Plan CRHA recognizes it did not submit timely AMCCs by the reporting deadline for CFP grant numbers VA36P016501-20, VA36P016501-21 and VA36P016501-22. To effectively avoid this for grant fund close outs, we are updating our check...
RE: Capital Fund Program Financial Reporting Finding Corrective Action Plan CRHA recognizes it did not submit timely AMCCs by the reporting deadline for CFP grant numbers VA36P016501-20, VA36P016501-21 and VA36P016501-22. To effectively avoid this for grant fund close outs, we are updating our checklist to ensure current and any future staff submits all reports correctly and within calendar deadlines. Further, our procedure will dictate that the CRHA accounting staff member(s) authorized and responsible for drawing federal funds in ELOCCS will prepare grant funds closing reports and documents, with subsequent review and submission to the HUD field office by the finance director.
The Property Manager will be responsible for completing all income verifications and calculations to ensure accuracy and compliance with HUD requirements. The income verification documentation and rent calculation worksheets will be reviewed and signed off by the Property Manager Supervisor, which i...
The Property Manager will be responsible for completing all income verifications and calculations to ensure accuracy and compliance with HUD requirements. The income verification documentation and rent calculation worksheets will be reviewed and signed off by the Property Manager Supervisor, which is the Chief Financial Officer (CFO) for Comprehend. This added level of oversight will strengthen interanl controls and help ensure that tenant and HUD rent portions are calculated correctly and supported by appropriate documentation.
Comments on the Finding and Each Recommendation: The Corporation did not make the total required reserve for replacement deposits during the year ended June 30, 2025, which resulted in the reserve for replacements account being underfunded by $1,205 as of June 30, 2025. The management agent should t...
Comments on the Finding and Each Recommendation: The Corporation did not make the total required reserve for replacement deposits during the year ended June 30, 2025, which resulted in the reserve for replacements account being underfunded by $1,205 as of June 30, 2025. The management agent should transfer funds of $1,205 from the operating account in order to bring the reserve for replacements account current. Action(s) taken or planned on the finding Management agrees with the recommendation. Management transferred $1,205 from the operating account to the reserve for replacements account on August 26, 2025. No further action is required.
Comments on the Finding and Each Recommendation: The Corporation's Flexible Subsidy Loan was due in full upon maturity of the Corporation's Section 202 mortgage loan, which occurred in March 2017. As of June 30, 2025, the Flexible Subsidy Loan has not been repaid and the Corporation is in technical ...
Comments on the Finding and Each Recommendation: The Corporation's Flexible Subsidy Loan was due in full upon maturity of the Corporation's Section 202 mortgage loan, which occurred in March 2017. As of June 30, 2025, the Flexible Subsidy Loan has not been repaid and the Corporation is in technical default on the Flexible Subsidy Loan. Management should continue communicating with HUD in order to obtain approval for the deferment request for the Section 201 Flexible Subsidy Loan. Action(s) taken or planned on the finding Management agrees with the recommendation. Management has submitted a request for deferment of the Flexible Subsidy Loan. Management is awaiting HUD approval of the deferment request.
Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – March 31, 2026
Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – March 31, 2026
Condition: The Corporation failed to refund a security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returne...
Condition: The Corporation failed to refund a security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely. Contact person responsible for corrective action: Sean Alexander, Vice President – Housing Accounting Completion Date: October 8, 2025
Condition: The Corporation failed to refund a security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returne...
Condition: The Corporation failed to refund a security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely. Contact person responsible for corrective action: Sean Alexander, Vice President – Housing Accounting Completion Date: November 8, 2024
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will re-evaluate controls around cost identification and authorization in efforts to minimize potential error going forward.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will re-evaluate controls around cost identification and authorization in efforts to minimize potential error going forward.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
MANAGEMENT AGREES WITH THE FINDING. THE FINANCIAL STATEMENTS WERE SUBMITTED TO HUD ON JANUARY 7, 2025.
MANAGEMENT AGREES WITH THE FINDING. THE FINANCIAL STATEMENTS WERE SUBMITTED TO HUD ON JANUARY 7, 2025.
Comments on Finding and Recommendation: The Corporation paid management fees of $1,675 in excess of the amount approved by HUD. The HUD approved management agent certification (Form HUD-9839-B) provides for the payment of management fees equal to 6.97% of residential and miscellaneous income collect...
Comments on Finding and Recommendation: The Corporation paid management fees of $1,675 in excess of the amount approved by HUD. The HUD approved management agent certification (Form HUD-9839-B) provides for the payment of management fees equal to 6.97% of residential and miscellaneous income collected. Action(s) taken or planned on the finding: Management agrees with the recommendation. The Agent intends to reimburse the Corporation the overpayment of management fees.
Program: Housing Choice Voucher (HCV) Program Finding No. 2024-001 Housing Choice Voucher & Emergency Choice Voucher, ALN #14.871 Compliance Requirement: Eligibility Type of Finding: Noncompliance, Significant Deficiency Corrective Action Overview The Authority acknowledges the finding and agrees th...
Program: Housing Choice Voucher (HCV) Program Finding No. 2024-001 Housing Choice Voucher & Emergency Choice Voucher, ALN #14.871 Compliance Requirement: Eligibility Type of Finding: Noncompliance, Significant Deficiency Corrective Action Overview The Authority acknowledges the finding and agrees that improvements are necessary to strengthen oversight and quality control of the annual recertification process. The Authority is committed to ensuring full compliance with HUD regulations and its Administrative Plan by implementing enhanced procedures, staff training, supervisory review, and ongoing monitoring. ________________________________________ Corrective Actions 1. Standardization of Recertification Process The Authority will update and standardize its annual recertification procedures to ensure that all required steps and documentation are completed consistently and in accordance with HUD regulations and the Administrative Plan. This will include the use of a standardized recertification checklist for each household file to verify that all required income verifications, third-party documentation, rent calculations, utility allowances, and eligibility determinations are obtained and retained. 2. Enhanced Supervisory Review and Quality Control The HCV Program Manager or designated supervisor will conduct a mandatory secondary review of all annual recertifications prior to final approval. This review will confirm that required documentation is complete, accurate, and properly filed before Housing Assistance Payments (HAP) amounts are finalized. Supervisory review will be documented and retained in the tenant file. 3. File Remediation and Backlog Review The Authority will conduct a comprehensive review of all active HCV participant files to identify missing or incomplete annual recertification documentation. Where deficiencies are identified, staff will obtain missing documentation and correct tenant rent and HAP calculations, as necessary. Any discrepancies identified during this review will be documented and resolved in accordance with HUD guidance. 4. Staff Training and Technical Assistance All HCV staff involved in the recertification process will receive refresher training on HUD annual recertification requirements, file documentation standards, and Administrative Plan provisions. Training will emphasize income verification requirements, timeliness standards, and proper file maintenance. Training completion will be documented and retained for monitoring purposes. 5. Ongoing Monitoring and Internal Audits The Authority will implement periodic internal file reviews, including quarterly quality control sampling of HCV recertification files, to ensure continued compliance. Results of internal reviews will be documented, deficiencies will be addressed promptly, and corrective actions will be tracked to completion. ________________________________________ Responsible Staff • Executive Director: Oversight and accountability • HCV Program Manager: Implementation of corrective actions and supervision • HCV Specialists: Completion of recertifications and file documentation • Quality Control Reviewer (or Designee): Ongoing monitoring and file reviews ________________________________________ Implementation Timeline • Within 30 days: o Implement standardized recertification checklist o Begin supervisory review of all annual recertifications • Within 60 days: o Complete staff refresher training o Begin file remediation review of active HCV participant files • Within 90 days: o Complete file remediation o Implement quarterly internal quality control reviews Expected Outcome Implementation of these corrective actions will ensure that annual recertifications are completed timely and accurately, required documentation is properly maintained, and tenant rent and HAP determinations are fully supported. These measures will strengthen internal controls, reduce compliance risk, and improve the Authority’s ability to demonstrate adherence to HUD regulations and its Administrative Plan.
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